State of Tennessee v. Charles Beaty

The State appeals from the trial court's dismissal of a three-count indictment based on the trial court's finding that there was an excessive delay in prosecuting the defendant, Charles Beaty. The State contends that the trial court erred in dismissing the indictment on finding a violation of the defendant's right to a speedy trial and due process. We conclude that the trial court correctly dismissed any offenses which were merely the reindictment of a previously dismissed case. However, the trial court erred in dismissing any new charges, because the defendant's right to a speedy trial was not violated and the defendant failed to show that he was prejudiced by the delay as required for due process relief. Accordingly, we remand for further proceedings in accordance with this opinion.